Tips on Writing GGNRA Comments

By sally - Posted on 20 May 2011

This Draft Rule is the final phase of the decades-long process to restrict where you can walk with a dog in the Golden Gate National Recreation Area. Many places where you can walk off-leash now will become no-dogs-allowed. This draft rule is worse than previous versions.

WE NEED PEOPLE TO SUBMIT COMMENTS BEFORE MAY 26, 2016.

Click here to read and comment on the draft rule. This site is where you can submit a comment on the plan before May 26, 2016.

Or you can mail or hand deliver a written comment to:
General Superintendent, GGNRA
Attn: Dog Management Proposed Rule
Fort Mason, Building 201
San Francisco, CA 94123

Click here to see maps of where dogs will be allowed at 22 sites in the GGNRA:

HOW TO COMMENT
Question any or all of the features of the proposed rule listed below. Also, include your personal experiences walking with dogs in the GGNRA. Comment on what impacts the proposed rule will have on you, your dogs, and your life. For example, “I’ve been walking at Fort Funston for over a decade and I have never seen a dog cause a problem for wildlife or other visitors” or “I can walk to Ocean Beach now from my home and these new restrictions will force me to drive to a city park to walk my dogs, increasing air pollution and contributing to congestion on city streets.”

Comment on the individual GGNRA sites and whether you agree or disagree with the changes to dog walking there. Comment on problems you have with small off-leash areas in city parks (e.g., too dusty, too many dogs in confined space). Comment on the benefits of dog walking, including off-leash dog walking, to you and how this rule will impact those benefits. Offer alternatives that you think would work better than what the Park Service has proposed.

Be sure to indicate your support for commercial dog walking in the GGNRA. The Park Service has made clear that they want people to comment on this one issue.

FEATURES OF THE DRAFT RULE
1) This is the largest single reduction in recreational access for people in GGNRA history. People are affected, not just dogs.
San Francisco:
People with dogs will be banned entirely (both on- and off-leash) from most of Ocean Beach (80%) and Fort Funston (60%) and the entire East Beach at Crissy Field. No off-leash at Baker Beach, Lands End, Fort Miley (with reduced on-leash at those sites). Remaining off-leash areas will be cut in size by over 50%.
Marin:
Only off-leash in Marin will be half-mile of Rodeo Beach, a cold, remote location with treacherous surf. Off-leash dogs banned from Muir Beach. Dogs banned on every trail leading out of Muir Beach, including fire roads, virtually stranding that community. On-leash trails cut from 24 miles to just 8 miles.
San Mateo:
There will be no off-leash anywhere in San Mateo. Rule will cut on-leash trails by 50-65%. There will be no loop trails, so you will only be able to walk out and back on same trail. Rule bans dog walking from many neighborhood trailheads.

2) The rule puts added restrictions on people who walk 4 to 6 dogs.
People walking 4-6 dogs will be banned everywhere in the GGNRA in the evenings and on weekends. They will be banned entirely (even on-leash) from Ocean Beach, from the Promenade at Crissy Field, from anywhere in San Mateo, and from all but one trail (Alta Trail, on-leash only) in Marin. They will be forced to get the same expensive permits as commercial dog walkers. This could have a substantial negative impact on rescues whose fosters often care for multiple dogs and need places to exercise and socialize their dogs.

3) The rule encourages Park Rangers to harass people walking with a dog.
They can ask you for proof of rabies vaccination, dog license, and a demonstration of immediate recall if the dog is off-leash. They can stop you whether your dog is on- or off-leash, and they can stop you any and every time they see you. The Park Service has budgeted $2.6 million to hire personnel to enforce the rule.

4) Further restrictions can happen without public input.
The rule allows the GGNRA Superintendent to arbitrarily impose new restrictions if she decides there’s not enough compliance with this rule. Within several years, there might not be any dog walking left anywhere in the GGNRA.

5) There’s been no adequate study of impacts of the rule on city parks.
The Park Service has never adequately studied the impacts on city parks if thousands of people and dogs are forced out of the GGNRA. In 2011, the SF Board of Supervisors made one request of the Park Service, and that was to study impacts on city parks. They have not done it.

6) There’s no evidence that dogs cause significant problems.
Two environmental impact statements (each 2,000+ pages) show no evidence that dogs cause significant impacts on wildlife, plants or other park visitors. Instead they talk about things that “could”, “might”, or “may” occur, with no evidence those impacts are occurring now – or ever happened – in the GGNRA.

7) The rule violates the mandate behind the creation of the GGNRA.
The GGNRA was created by Congress “to concentrate on serving the outdoor recreation needs of the people of this metropolitan area.” Dog walking was specifically mentioned as a recreational use in Congress. The proposed rule violates this mandate by removing a long-standing recreational use, for no good reason. Unelected bureaucrats in the Park Service have decided they want to manage this highly modified, urban recreation area the same way they manage a remote, pristine wilderness. They removed recreation as a guiding principle for the GGNRA, and this dog rule is the first step in their plans to cut access for all recreational users.

8) The Park Service has ignored overwhelming opposition to its dog plans.
At every stage of the process to develop this rule, public comment has been overwhelmingly opposed to restrictions on access for people walking dogs. Nearly all local elected officials, including the Boards of Supervisors of all three counties with GGNRA land, have gone on record opposing the restrictions. Yet, at every stage of the process, the Park Service has forged ahead with the plan it wants – cutting off-leash access by 90% – making only minor, cosmetic changes to their original plan. The Park Service has only listened to people who agree with what it wants to do, completely ignoring the clearly expressed will of the majority of people who do not want to restrict recreational access in this National Recreation Area.